A question and answer session with Sam Church, Managing Director of The Safety Department, Inc. published in ForConstructionPros.com.
Sam Church, Managing Directory of The Safety Department, Inc., answers questions about the proper way to educate new employees
about OSHA and company safety.
Q: When an employee joins a construction crew, especially one who may be fresh out of school or never been on a jobsite before, what is the best approach to bring this person up-to-speed on adhering to OSHA safety regulations?
A: The project manager or job foreman should have a brief interview with all new employees. He should first ascertain whether the new-hire has had any OSHA authorized curriculum (OSHA-10 hour, e.g.) as part of his technical education, training or apprenticeship. If he has not had such instruction, he needs to apply or develop a new employee safety orientation before putting someone to work. If he has had such training, the project manager or foreman can probably skip directly to his company and site-specific requirements in OSHA’s “Big Four” at construction sites: Fall Protection, Electrical Safety, “Caught Between” accidents and “Struck By” accidents. He should also emphasize site- and job-specific personal protective equipment (PPE) requirements. He should not overlook Hazard Communication (MSDS, chemical inventory, etc.), as this is almost always the No. 1 most frequently issued citation. Finally, if possible, it’s always wise to use the buddy system with new or inexperienced workers. Pair the new guy up with a safe, experienced employee for a few days.
Q: How should this person be made aware of a company’s additional safety practices?
A: Through a detailed safety orientation (see above). Employers should avoid the temptation to buy a canned program and use it as their only source of safety training. The practice of seating new hires in a job site trailer, slapping a video in the machine and leaving the room is woefully inadequate, not to mention failing to meet OSHA’s requirements for “site-specific” safety training. Live instruction, with an opportunity for new employees to ask questions and interact with a live human being is always best.
Q: Who is ultimately responsible if an employee violates an OSHA safety regulation?
A: The employer is ALWAYS the party cited by OSHA. There is NO legal authority provided in the Occupational Safety & Health Act that enables OSHA to cite employees.
Q: How much safety training should be done before the new employee steps out onto the jobsite?
A: It’s difficult to specify a certain quantity of safety training time. OSHA has different training requirements for many different types of job sites, according to the exact job tasks a given worker may be called upon to perform. Obviously, a welder or ironworker will have greatly different training requirements from a day laborer. And equipment operators (cranes, boom lifts, graders, powered industrial trucks, etc.) will need specialized instruction very different from drywallers. A handy tool for determining what training to give and to whom can be found on OSHA’s web site (www.osha.gov) Training Requirements in OSHA Construction Industry Standards and Training Guidelines (or http://www.osha.gov/doc/outreachtraining/htmlfiles/osha2254.html). This document breaks down required training according to subparts within the construction standards (Subpart E Personal Protective Equipment, Subpart L Scaffolding, etc.)
Q: Who should be in charge of the safety education?
A: If an employer is too small to hire a safety compliance officer, then the task needs to fall to someone who sees the employees most often: a project manager, jobsite foreman, etc. There’s really no one better suited to oversee the day-to-day safety of individual workers.
Q: What are some of the common safety mistakes new employees will make when they are first on the jobsite?
A: Most common, whether a new employee or experienced, is getting in a hurry. This leads to taking shortcuts, which, without doubt eventually leads to accidents. Other frequent mistakes are improper use of (or no) PPE. It’s not unusual to observe workers using grinders, sparks and metals shards flying everywhere, to have no face shield and maybe no protective glasses (both are required for this task). Also, a general lack of hearing protection. Power equipment almost always creates unsafe decibel levels. Even when the equipment operator uses protection, many of the workers in close proximity will be without ear plugs. Finally, constant awareness of unprotected floor / working surfaces that are six feet or higher from the next level. Falls continue to be the leading cause of fatalities at jobsites.
Q: How should feedback be given if a new employee violates an OSHA or company safety policy?
A: A progressive discipline is best to protect both workers and employers. Something along the lines of (1) verbal warning & re-instruction; (2) written or “formal” warning & re-instruction; and (3) suspension and / or dismissal. Workers should be given the opportunity to make honest mistakes and to learn from them. Employers have an ethical, legal and financial obligation to document their good faith efforts to enforce their company’s rules and OSHA’s safety regulations.
Q: How can co-workers assist in the learning process for the new employee?
A: On an ideal jobsite, workers would take a proactive approach to preventing injuries to co-workers through on-the-spot warnings and reminders. There is no more effective reinforcement than an immediate (to the behavior) verbal reminder. Safety training should never end in the classroom or at the toolbox talks. Beyond the simple “caring for our brother” principles, co-workers should always keep in mind that an unsafe worker next to them presents an increased likelihood for injury to everyone. Also, a serious injury could shut down a jobsite, hitting every employee in the pocketbook.
Q: What other information or best practices are there to ensure that new employees will keep themselves and their co-workers safe?
A: Other than the information provided by a fulltime safety officer, the OSHA web site (www.osha.gov) is a rich source of information. The site is constantly improving and has become much more user-friendly. OSHA has developed “Quick Takes” which give brief but valuable snippets of advice, best practices, warnings, etc. All employers and workers should visit this site frequently and take advantage of the FREE, lifesaving information there.